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Koehnke v. Remley & Sensenbrenner, S.C.

United States District Court, E.D. Wisconsin, Green Bay Division

August 27, 2019

JOEL KOEHNKE, Plaintiff,
v.
REMLEY & SENSENBRENNER, S.C., Defendant.

          AGREED TO PROTECTIVE ORDER

          William C. Griesbach, Chief Judge

         Based on the joint motion of the parties and the representations set forth therein, the Court finds that the exchange of sensitive information between or among the parties and/or third parties other than in accordance with this Order may cause unnecessary damage and injury to the parties or to others. The Court further finds that the terms of this Order are fair and just and that good cause has been shown for entry of a protective order governing the confidentiality of documents exchanged by the parties, documents produced in discovery, answers to interrogatories, answers to requests for admission, and deposition testimony.

         IT IS THEREFORE ORDERED THAT, pursuant to Fed.R.Civ.P. 26(c) and Civil L.R. 26(e):

         (A) DESIGNATION OF CONFIDENTIAL OR ATTORNEYS' EYES ONLY INFORMATION. Designation of information under this Order must be made by placing or affixing on the document or material, in a manner that will not interfere with its legibility, the words “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS' EYES ONLY.”

         (1) One who produces information, documents or other material may designate them as “CONFIDENTIAL” when the person in good faith believes they contain trade secret or nonpublic confidential technical, commercial, financial, personal, or business information.

         (2) One who produces information, documents, or other material may designate them as “CONFIDENTIAL - ATTORNEYS' EYES ONLY” when the person in good faith believes that they contain particularly sensitive trade secrets or other nonpublic confidential technical, commercial, financial, personal or business information that requires protection beyond that afforded by a “CONFIDENTIAL” designation.

         (3) Except for information, documents, or other materials produced for inspection at the party's facilities, the designation of confidential information as “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS' EYES ONLY” must be made prior to, or contemporaneously with, their production or disclosure. In the event that information, documents, or other materials are produced for inspection at the party's facilities, such information, documents or other material may be produced for inspection before being marked confidential. Once specific information, documents, or other materials have been designated for copying, any information, documents, or other materials containing confidential information will then be marked “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS' EYES ONLY” after copying but before delivery to the party who inspected and designated them. There will be no waiver of confidentiality by the inspection of confidential information, documents, or other materials before they are copied and marked confidential pursuant to this procedure.

         (4) Portions of depositions of a party's present and former officers, directors, employees, agents, experts and representatives will be deemed confidential only if designated as such when the deposition is taken or within 30 days of receipt of the deposition transcript.

         (5) If a party inadvertently produces information, documents, or other material containing “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS' EYES ONLY” information without marking or labeling it as such, the information, documents or other material shall not lose its protected status through such production and the parties shall take all steps reasonably required to assure its continued confidentiality if the producing party provides written notice to the receiving party within 10 days of the discovery of the inadvertent production, identifying the information, document or other material in question and of the corrected confidential designation. No. party shall be found to have violated this Protective Order for failing to maintain the confidentiality of material during a time when that material had not been designated, even where the failure to so designate was inadvertent and where the material is subsequently designated “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS' EYES ONLY.”

         (B) DISCLOSURE AND USE OF CONFIDENTIAL INFORMATION.

         Information, documents, or other material designated as “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS' EYES ONLY” under this Order must not be used or disclosed by the parties or counsel for the parties or any persons identified in subparagraphs (B)(1) and (2) below for any purposes whatsoever other than preparing for and conducting the litigation in which the information, documents, or other material were disclosed (including appeals). The parties must not disclose information, documents, or other material designated as “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS' EYES ONLY” to putative class members not named as plaintiff in putative class litigation unless and until one or more classes have been certified.

         (1) “CONFIDENTIAL INFORMATION.” The parties and counsel for the parties must not disclose or permit the disclosure of any information, documents or other material designated as “CONFIDENTIAL” by any other party or third party under this Order, except that disclosures may be made in the following circumstances:

(a) Disclosure may be made to counsel for the parties and to employees of counsel for the parties who have direct functional responsibility for the preparation and trial of the lawsuit. Any such employee to whom counsel for the parties makes a disclosure must be advised of, and become subject to, the provisions of this Order requiring that the information, documents, or other material be held in confidence.
(b) Disclosure may be made only to employees of a party required in good faith to provide assistance in the conduct of the litigation in ...

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